Richard Paul Mann, Appellant v. the State of Texas

Summary

The Court held that the trial court’s isolated erroneous jury instruction concerning the burden of proof was not structural and must be reviewed under the Abdnor/Almanza framework, requiring the appellant to show egregious harm. Because the Court of Appeals applied the general harmless‑error rule Rule 81(b)(2) incorrectly, the judgment was vacated and remanded for further proceedings. The Court distinguished Sullivan v. Louisiana, concluding that a partial error does not mandate automatic reversal. Justice Keller dissented, arguing that the error was not structural and that the appellate court’s harmless‑error finding should be affirmed.